Below is the letter that I read to the Board of Trustees for Sweetwater County School District Number One. This is something that ALL parents and community members should be aware of and concerned about. Our local school boards will be entering into an agreement (MOU) that they have not officially agreed too. In doing so, they are giving away their power to represnt YOU as parents and community members, especially when it comes to your children’s data. We aren’t talking about the data they have always taken on our children. This is a statewide inter-operable (shares with other agencies) system that will share ALL information that could include a health record or disciplinary record from P20 (preschool through college and the workforce) system.
You may read the letter below or listen to me present to the board in the video recording my husband took (forgive the amateur video – but the sound system is great!)
My name is Christy Hooley and I am a teacher from Sweetwater County School District #2. I taught both 5th and 6th grade at Monroe Intermediate School. I recently resigned my position to focus on an issue that is dear to my heart, the Common Core State Standards and the various issues it brings to teachers and students across our state and nation. In doing so I have found others that have the same concerns, and I stand here representing the group, Wyoming Citizens Opposing Common Core.
One of these key issues that comes along with the CCSS is the creation of the State Longitudinal Database that will be inter-operable with other agencies. Due to some questions arising from this concern the Wyoming Department of Education released a document entitled “Data Governance” for districts to distribute to parents concerned about data. The document covers four “Commonly Asked Questions about Student Data”. While I appreciate the effort of the WDE to be both transparent and informative, the document does not cover many key issues, nor does it provide any links or references as to fact check sources.
These issues should be addressed and communicated to parents in our community as well as around the state. The creation of the State Longitudinal Data System is a key issue in education reform, and parents have many questions surrounding its creation and use. Please look over the MOU (memorandum of understanding), which is an agreement between 20+ state agencies to begin sharing student data via the State Longitudinal Data System. You will find that it states, “The creation of the P20 SLDS is called for in the 2012 Legislative Session Enrolled Act 29 Section 326. The creation of P20 SLDS and data sharing shall fulfill the requirements established by the Wyoming Accountability in Education Act”
Basically, what you have in front of you, to the best mine and our group’s knowledge is… that all of the data that is collected by the local school districts, which you represent, will go into this system. The Department of Ed is going to sign for you…in doing so you stating that all agencies listed can receive information. This is a serious local control issue, this document says districts are required to collect this information, but you are not required to sign this agreement. This is the information on our kids and families, and it is not just being distributed to every educational entity in the state of Wyoming, but to Department of Workforce Services, Department of Family Services, Department of Health, and any other agency they deem. This is something that should be brought to the public’s attention as well as our representatives. I implore that you make this a priority quickly!
As you may be aware I have been giving presentations in our community and around our state concerning education reform and its most recent reform with the Common Core State Standards. I am often asked questions that I cannot answer by concerned parents. You are elected to represent our community, and should know the concerns that I’m often approached with. I would like to give you an opportunity to address these concerns.
These are questions that I would pose as “Commonly Asked” by parents in our district and across our state:
1) What is the purpose of the State Longitudinal Data System?
2) The recent changes to FERPA by the US Department of Education has allowed for sharing of student data in the SLDS. What state agencies will now be sharing student data?
3) What data dictionary will be used to collect student data from the districts to the WDE for the SLDS?
4) How are parents notified of what data will be collected from their student at the district level and sent to the state?
5) How does WDE notify parents if a data breach occurs?
6) What legal recourse/penalties does an agency face in the event of a data breach on a child’s educational record?
7) How long is student data stored, and how is it destroyed once it is no longer needed?
8) What third party entities have access to student data via the SLDS?
This is the heart of the concerns that parents have about data being collected on their children. The recent changes to FERPA undermine parental consent provisions. It is my understanding that there is not currently Wyoming law that outlines data breach reporting requirements or penalties in the event that a breach occurs. I would ask you as a board to seek answers to these questions from the WDE Data Governance Contacts.
Furthermore, I would ask that you familiarize yourself with the Privacy Bill known as Senate File 36 that was discussed by the Committee on Statewide Education Accountability on Dec. 10th. It does not include the SLDS, and therefore does not do enough to protect our children’s data. If a health record becomes part of a student’s educational file, it is no longer protected. I would recommend that all student disciplinary and health records be exempt from educational records and remain confidential under all circumstances.
I am not suggesting that Wyoming is sharing this data currently, however there is nothing strong preventing them from doing so, plus school systems are moving more and more to commonality and disaggregating (personally identifiable) student data. This can be seen by all those partnered with the Data Quality Campaign and policies held by the Council of Chief State School Officers.
I invite each one of you to attend my next presentation, so you may also become informed on both sides of the education reform issues and better understand the questions and concerns parents may come to you with. I will be presenting next on January 24th at 7PM at the Green River Library and again at the White Mountain Library in Rock Springs on January 30th, at 7PM.
I hope to hear back from you concerning this extremely important issue.